Code of Conduct

Our Business

Throughout our businesses across Europe, the Americas and Asia, Pattonair is committed to the highest standards of ethics and business conduct. We strive to provide a world class service to our worldwide customers by living out our core values: Build with Integrity, Fairness and Trust; Challenge and Innovate; Always Put Outstanding Service First and Make Ambition Work. In abiding by these values we aim to uphold our reputation for being reliable and acting with integrity, respecting the laws, regulations, traditions and cultures of the countries in which our customers, we and our suppliers operate. We pride ourselves on high standards of service and the professional and ethical conduct of all our employees who act on behalf of Pattonair and who are expected to treat compliance to this Code of Conduct as a key element of their daily working lives.

Similarly, our suppliers are responsible for ensuring that their directors, officers, employees, representatives and suppliers understand and comply with the expectation in this Code of Conduct. However, this Code of Conduct is not intended to be all inclusive and suppliers are obliged to ensure appropriate compliance to all applicable laws, regulations, traditions and cultures of the countries in which they and their suppliers operate.

This Code of Conduct applies to all customers, employees and suppliers and sets a minimum standard for expected behaviour and helps to sustain and enhance our joint reputation and contribute to Shareholder long-term value creation. We expect that Suppliers will support Pattonair with appropriate data and site access plus the provision of additional data, certificates etc. evidencing compliance and take prompt action to correct any non-compliance.

Legal Compliance and Business Ethics

General Compliance

Pattonair, its customers and suppliers are required to comply with all the laws and regulations of the countries in which they operate. As a minimum this includes compliance with laws prohibiting any form of corruption, bribery, sales or shipments to embargoed countries and the restriction of imports or exports where necessary, as well as any laws concerning the governance of business transactions.

Bribery and Corruption

Anything which constitutes or creates an unfair or improper business advantage should be avoided. This may even be something which appears to influence someone’s business judgement. Bribes may not be offered, promised, demanded, given or accepted in order to gain such an advantage including the provision of excessive or frequent gifts or entertainment.

Conflicts of Interest

Employees should recognise personal relationships and situations where it will be difficult to apply objectivity. All instances of an actual or apparent conflict of interest must be reported to Pattonair. This includes instances of where personal relationship can impact on a business decision or where an employee has an ownership or financial interest in Pattonair, a supplier or customer.

Legal and Fair Competition

Pattonair competes aggressively and fairly in its market sectors. We do not collude with our competitors on pricing matters, inventory levels, products, bids or sales agreements. We expect our supply chain to adhere to the same. Pattonair complies with all competition in business transactions and does not engage in any deceptive practices or espionage to get information on our competitors.

Government Procurement

All government requests or investigations received by Pattonair are fully cooperated with. This includes compliance with government legislation regarding fair competition, specification conformance, government accounting and pricing requirements. All government requests are responded to in an accurate and truthful manner.

Human Rights

Pattonair maintains the highest respect for the protection and enforcement of human rights. Pattonair, its customers, suppliers and employees are responsible for upholding these values. We do not accept discrimination of any kind and being compliant with modern slavery and human-trafficking law, we will not tolerate compulsory, forced or child labour. Pattonair and our trading partners must comply with all relevant child labour laws and should not employ anyone who is under the age of fifteen or, where it is higher, the mandatory school leaving age in that locality. All employees, stakeholders and suppliers are respected by all Pattonair staff.

International Trade

Pattonair complies with all UK, US and international laws and regulations in its global trade. This covers the export and import of goods and transfer of goods, technologies and services, including both civil and military applications. We accurately report our importing and exporting transactions, seeing Trade Compliance knowledge a fundamental aspect of our business strategy.

Quality

Pattonair focusses on quality to meet our customers’ diverse needs including delivering products and services on time, to the correct specification and at the agreed price. To do this we expect our suppliers to comply with all quality control requirements, both dictated by industry governing legislation and via specific customer requirements. Any issue regarding safety should be reported immediately.

Integrity

Integrity is the core value of Pattonair’s Code of Ethics. Pattonair is committed to conducting business fairly and honestly. All Pattonair employees are expected to act, at all times and in all circumstances, with the highest sense of integrity on behalf of the Company, acting in a manner that protects and enhances the Company’s corporate reputation. To this end:

Pattonair employees shall be ‘straightforward and honest in all professional and business relationships.’

No employee shall engage in personal activities or pursue financial or business interests which might give rise to, or give the appearance of, conflicts of interest with Pattonair, or which might compromise their ability to meet the responsibilities of their job.

Pattonair does not offer, promise, give, demand or accept bribes or other unethical advantage in order to obtain, retain or give business or other advantage.

Pattonair employees who have access to privileged information (including proprietary and confidential information, whether belonging to Pattonair or others) must not use it to achieve personal gain for themselves or others.

Pattonair employees must ensure proper and responsible use of all Pattonair’ assets, including physical property, intangible assets, IT equipment and communication resources.

Protection of Information & Assets

Trading partners and employees shall respect intellectual property rights and safeguard their own and third parties’ information, including the protection of IT assets from theft or misappropriation. Transfer of intellectual property, technology and know-how will be undertaken in a manner that protects intellectual property rights.

Monitoring and Record Keeping

Trading partners and employees shall have processes to identify, understand, and implement applicable laws including regulations and requirements of this code. All stakeholders shall maintain documents and records to ensure regulatory compliance, and compliance with this code, and will make these available to the relevant parties on request.

Workplace

Pattonair is built upon honesty, integrity and trust and we are committed to ensuring fair employment practices. This includes complying with legislation on all matters of employment including working time, wages, diversity, equality and prohibiting discrimination. Our statement on Modern Slavery is available to support this.

Our facilities are not only safe places to work with compliance to Health Safety and Environment practices but they encourage team working, innovation and flexibility. Compliance with laws is something we strive to exceed upon. Our no tolerance approach to intoxication at work is also supported by our wellbeing practices. It is expected that our suppliers operate to the same standards as ourselves and are able to demonstrate good HSE practices in all of their operations.

We work in diverse locations but operate within standard procedures for health and safety at work. We report annually on not only our results but our aims. Our Corporate Social Responsibility report is available to support this.

Pattonair and our supply chain, from time to time, may come into contact with conflict minerals. It is our expectation that we have controls in place to minimise this requirement and reliance. By focusing on alternative sources we aim to minimise this and our risk to the environment.

Health Safety and the Environment

Pattonair promotes environmental excellence across all facilities and expects the same throughout the supply chain in order to reduce our environmental footprint. We actively reduce the production of and encourage the recycling of waste; whilst also promoting car sharing and cycle to work schemes for our employees. This is communicated throughout the organisation in compliance with environmental legislation and ISO14001:2015.

Corporate Social Responsibility and Community

We operate in locations across the world yet wherever we are based we act with integrity as good corporate citizens. We focus on employee safety, bringing fairness and consistency in each region we operate in, and working with local communities to have a positive impact on the local area. Our Corporate Social Responsibility report is available to support this.

Applicability

The integrity of Pattonair ultimately depends upon the individual actions of our directors, officers, employees and representatives, all over the world. Each one is personally responsible and accountable for compliance with this Code.

Code Compliance

All entities are responsible for ensuring compliance to this Code of Conduct with their directors, officers, employees, representatives and suppliers and any suspected non-compliance or questions relating to expectations should be addressed to: codeofconduct@pattonair.com

All correspondence to the above will be treated confidentially and investigated properly and promptly whether it be raised internally or externally.

Pattonair operates an anti-retaliation policy. Actions cannot be taken against individuals for raising concerns in good faith.